Section 1886(d)(3)(E) of the Social Security Act (the Act) requires that, as part of the methodology for determining prospective payments to hospitals, the Secretary must adjust the standardized amounts “for area differences in hospital wage levels by a factor (established by the Secretary) reflecting the relative hospital wage level in the geographic area of the hospital compared to the national average hospital wage level.” This adjustment factor is the wage index. Hospital geographic areas (labor market areas) are defined based on the definitions of Core-Based Statistical Areas (CBSAs) established by the Office of Management and Budget. The wage index also reflects the geographic reclassification of hospitals to another labor market area in accordance with sections 1886(d)(8)(B) and 1886(d)(10) of the Act.
The Act further requires that the wage index be updated annually based on a survey of wages and wage-related costs of short-term, acute care hospitals. Data included in the wage index derives from the Medicare Cost Report, the Hospital Wage Index Occupational Mix Survey, hospitals' payroll records, contracts, and other wage-related documentation. In computing the wage index, an average hourly wage (AHW) is derived for each labor market area. The AHW for a geographic area is computed as total wage costs divided by total hours for all hospitals in the geographic area, and a national AHW is computed as the total wage costs divided by total hours for all hospitals in the nation. A labor market area's wage index value is the ratio of the area's average hourly wage to the national average hourly wage. The wage index adjustment factor is applied only to the labor portion of the standardized amounts.
The wage index review process is run annually by the Centers for Medicare and Medicaid Services (CMS) during the federal fiscal year. The Wage Index Navigator (WIN) system includes functionality to help hospitals and hospital/health systems in reporting and complying with this process. The typical wage index review process includes the following:                1. October—Release of the preliminary fiscal year wage index public use file (PUF).        2. December—Deadline for fiscal intermediaries (FIs) to have received the hospital's request for revisions to their Worksheet S-3 wage data and occupational mix data as included in the October PUF and provide documentation to support the hospital's request.        3. February—Deadline for FIs to complete desk reviews for hospital wage index data and transmit revised Worksheet S-3 data and occupational mix data to CMS' Division of Acute Care (DAC).        4. February—Deadline for FIs to notify State hospital associations regarding hospitals that fail to respond to issues raised during the desk review.        5. February—Release of revised fiscal year wage index and occupational mix files as PUFs on the CMS web site.        6. March—Deadline for hospitals to submit requests (including supporting documentation) for corrections to errors in the February PUFs due to CMS or FI mishandling of wage index data or revisions of desk review adjustments to their wage index data.        7. April/May—Proposed rule is published, which includes proposed wage index values.        8. April—Deadline for FIs to transmit final revised wage index data for inclusion in the final wage index.        9. April—Deadline for hospitals to appeal FI determinations and request CMS intervention in cases where the hospital disagrees with the FI's determination.        10. Late April—Wage index compiled and sent by CMS to FIs for verification.        11. May—Release of final wage index and occupational mix data PUFs on the CMS web site.        12. June—Deadline for hospitals to submit corrections to both CMS and their FI to correct errors due to CMS or FI mishandling of the final wage index and occupational mix data.        13. August—Approximate date for publication of the final rule; wage index rule includes final wage index corrections.        14. October—Effective date of wage index.        
The Wage Index Navigator (WIN) system can be used by hospitals and hospital systems to input, compile and report wage index and occupational mix information. The majority of the processing and calculation of the WIN system are focused on the October PUF and the December filing of the hospital's request for revisions to their Worksheet S-3 wage data and occupational mix data as included in the October PUF, and the documentation to support the hospital's request. The majority of the processing after the December filing of the hospital's request is directed towards reporting and comparison of later publications and submissions until the next filing. An embodiment of the WIN system has been implemented as a web-based system. The WIN system can include functionality to:                Guide an end user through a set of questions, queries and tasks that will provide rigor and consistency to the compilation and reporting process;        Provide checks and balances that steer the end user towards submitting correct and complete data;        Provide a dashboard utility that manages the process and tactically assists medical facilities in completing the process;        Provides flexibility in allowing an end user the option of either importing or “keying-in” certain data elements;        Import publicly available and other hospital or relevant data;        Manage data by allowing supporting documentation to be uploaded for submission purposes and stored for future reference;        Generate reports to assist hospitals and hospital systems with compiling, filing and decision-making and with communicating with other hospitals; and        Maintain compliance with current CMS rules and regulations.        
Terms relevant to the description of the WIN system are defined throughout this document. Some introductory definitions are provided here for an easier understanding of the description, and these definitions are augmented by more detailed definitions provided throughout this disclosure. The “Average Hourly Wage” (AHW) represents an average hourly wage dollar amount. The “AHW Index Factor” represents the ratio of the AHW for a CBSA to the AHW for the nation. A “Core Based Statistical Area” (CBSA) represents a geographic area in which a particular hospital's wage index is grouped. A “Fiscal Intermediary” (FI) is a reviewer appointed by the CMS that performs a desk review of a hospital's wage index submission and reports to the CMS. The “Federal Register” is a publication of the federal government that includes data from the CMS used as an input to the WIN system. The “Public Use Files” (PUFs) are data files published periodically by the CMS and are described in more detail below. The PUFs are currently published in October, February, May and August which may be referred to herein as the October PUF, February PUF, May PUF and August PUF, respectively. An Electronic Cost Report (ECR) is a report generated annually for or by a hospital that contains information useful for the WIN system. The “S-3” refers to Worksheet S-3, Parts II & III which are included in the PUFs published by CMS. The “Initial S-3” refers to the initial version of the S-3, usually generated from the ECR or the October PUF. The “Proposed S-3” is generated by the WIN system as part of the proposed adjustment listing. The “Revised S-3” refers to the S-3 that comes back from the FI desk review.
A healthcare wage index reporting method is disclosed that includes providing questions and tasks through an electronic user interface to collect information for filling out a wage index and occupational mix report; electronically receiving responses to the questions and tasks; processing the responses to complete the wage index and occupational mix report; checking the responses to detect inconsistencies or errors; generating notices of detected inconsistencies or errors in the wage index and occupational mix report; tracking progress in completing the wage index and occupational mix report; and generating a completed wage index and occupational mix report for submission to a recipient. The recipient can be a fiscal intermediary that communicates with the Centers for Medicare and Medicaid Services (CMS). The method can also include displaying a dashboard showing progress of completing the wage index and occupational mix report, and current results for the wage index and occupational mix report. The method can also include validating the completed wage index and occupational mix report before submission; and protecting the validated wage index and occupational mix report from further modification.
The healthcare wage index reporting method can also include separating the wage index and occupational mix report into a plurality of sections; delegating each of the plurality of sections to a coordinator for completion; and for each completed section of the plurality of sections, compiling the information from the completed section to complete the wage index and occupational mix report. The method can also include tracking the progress toward completion of each delegated section, displaying a progress monitor showing the progress toward completion of each delegated section; and generating a notification message when each delegated section is completed.
The healthcare wage index reporting method can also include importing an electronic data file, storing the data in the imported electronic data file in memory; and processing the data from the imported electronic data file to complete the wage index and occupational mix report. The electronic data file can be a wage index and occupational mix public use file (PUF). The electronic data file can be used to pre-populate responses. Notifications can be generated of differences between information in the wage index and occupational mix report and information received from the electronic data file. In some embodiments, the notifications are only generated when the difference between information in the wage index and occupational mix report and information received from the electronic data file exceeds a threshold for that response. The threshold for generating a notification can be different for different information in the wage index and occupational mix report. A discrepancy report can be generated that shows differences between information in the wage index and occupational mix report and information received from the electronic data file.
Generating notices of detected inconsistencies or errors can include automatically notifying a user of a detected error; and not permitting progress in the wage index reporting process until the detected error is corrected. The healthcare wage index reporting method can also include providing a user-selectable link to more detailed instructions for responding to a particular question or task; and displaying more detailed instructions for responding to the particular question or task when the user-selectable link is selected. The more detailed instructions can include a worksheet or a series of questions for deriving the desired response to the particular question or task.
Receiving responses can include receiving supplemental attachment files supporting a response. The healthcare wage index reporting method can also include preparing workpapers supporting a particular response to a question or task; and attaching the workpaper to an appropriate portion of the wage index and occupational mix report. Preparing workpapers supporting a particular response to a question or task can include providing a workpaper template for collecting the supporting information for the particular response. The healthcare wage index reporting method can include electronically receiving a comment associated with one of the responses to the questions and tasks, the comment providing a user explanation of the response; and associating the comment with the one of the responses to the questions and tasks. The method can also include uploading audited financial statements; and reconciling the wage index and occupational mix report against the uploaded audited financial statements. The method can include selecting supporting documentation to be submitted with the completed wage index and occupational mix report.
The healthcare wage index reporting method can include generating prompts based on responses to the questions and tasks; and displaying the prompts as part of future questions and tasks provided to collect information for filling out a wage index and occupational mix report. The method can also include determining future questions and tasks to be provided based upon responses to previous questions and tasks. The method can also include generating reminders of time left for submission of the wage index and occupational mix report.
The healthcare wage index reporting method can include generating user-requested reports, for example an analysis report for review of current status of the wage index and occupational mix report; or an impact report showing the impact of proposed changes to the wage index and occupational mix report; or a proposed adjustment listing showing the differences between the current wage index and occupational mix report and a revision to the wage index and occupational mix report; or a county reclassification summary report showing the financial impact of county reclassification within a core based statistical area (CBSA); or an estimated wage index and occupational mix report based upon currently received information. The impact report can be generated for a selected core based statistical area (CBSA).
The healthcare wage index reporting method can include maintaining an audit log recording all responses and the source of each response. The method can also include receiving user messages for posting on a system bulletin board; receiving bulletin board responses responding to posted messages on the system bulletin board; associating each bulletin board response with the appropriate posted message; and deleting each posted message and any associated responses after a designated time period.
A healthcare wage index reporting system is disclosed that includes an electronic user interface, a processor, a validation module, an electronic dashboard and a finalization module. The electronic user interface provides questions and tasks to collect information for filling out a wage index and occupational mix report, and receives responses to the questions and tasks. The processor processes the responses to complete the wage index and occupational mix report. The validation module checks the responses to detect inconsistencies or errors in the wage index and occupational mix report, and generates notices of detected inconsistencies or errors in the wage index and occupational mix report. The electronic dashboard tracks progress in completing the wage index and occupational mix report. The finalization module generates a completed wage index and occupational mix report for submission to a recipient. The recipient can be a fiscal intermediary that communicates with the Centers for Medicare and Medicaid Services (CMS).
The electronic user interface can import and store electronic data files, and the processor can process the data from the imported electronic data files to complete the wage index and occupational mix report. The electronic data file can be a wage index and occupational mix public use file (PUF). The processor can pre-populate responses based on the electronic data file. The validation module can generate notifications of differences between information in the wage index and occupational mix report and information received from the electronic data file. In some embodiments, the notifications are only generated when the difference between information in the wage index and occupational mix report and information received from the electronic data file exceeds a threshold for that response. The validation module can generate a discrepancy report showing differences between information in the wage index and occupational mix report and information received from the electronic data file. The validation module can automatically notify a user of a detected error; and prevent further progress in the wage index reporting process until the detected error is corrected.
The healthcare wage index reporting system can include a help module for providing more detailed instructions for responding to the particular question or task when a user-selectable link is selected. The help module can provide a worksheet or a series of questions for deriving the desired response to the particular question or task.
The electronic user interface can accept supplemental attachment files supporting a response. The electronic user interface can display templates for collecting data and preparing workpapers to support a particular response to a question or task. The electronic user interface can accept audited financial statements; and the validation module can reconcile the wage index and occupational mix report against the uploaded audited financial statements. The electronic user interface can accept comments associated with one of the responses to the questions and tasks, where the comment provides a user explanation of the response. The healthcare wage index reporting system can include a reviewer module for a reviewer to respond to the user explanation in the comment field. The reviewer module can include a deletion function for deleting the comment field.
The finalization module can validate the completed wage index and occupational mix report before submission; protect the validated wage index and occupational mix report from further modification, and electronically submit the completed wage index and occupational mix report to the recipient. The finalization module can select supporting documentation to be submitted with the completed wage index and occupational mix report.
The processor can generate prompts based on responses to the questions and tasks; and the electronic user interface can display the prompts as part of future questions and tasks provided to collect information for filling out a wage index and occupational mix report. The processor can determine future questions and tasks to be provided through the electronic user interface based upon responses to previous questions and tasks. The processor can generate reminders of time left for submission of the wage index and occupational mix report.
The healthcare wage index reporting system can include a report module for generating user-requested reports, including an analysis report to review the current status of the wage index and occupational mix report; an impact report showing the impact of proposed changes to the wage index and occupational mix report; a proposed adjustment listing showing the differences between the current wage index and occupational mix report and a revision to the wage index and occupational mix report; a county reclassification summary report showing the financial impact of county reclassification within a core based statistical area (CBSA); or an estimated wage index and occupational mix report based upon currently received information.
The healthcare wage index reporting system can include an audit module for maintaining an audit log recording all responses and the source of each response. The healthcare wage index reporting system can also include a bulletin board module for receiving bulletin board posts, receiving bulletin board responses associated with bulletin board posts, and deleting each bulletin board post and any associated responses after a designated time period.